BEFORE THE 

FEDERAL AVIATION ADMINISTRATION 


WASHINGTON, D.C. 


* 

In the Matter of the Petition of 	 * 

* 

CHAMPLAIN ENTERPRISES, INC. * 

d/b/a COMMUTAIRIUNITED EXPRESS * Regulatory Docket No. 

* 

for an exemption from FAR 121.344(e) 	 * 

* 

PETITION FOR EXEMPTION 

Communications with respect to this document should be sent to: 

James W. Tello 

LAW OFFICES OF JAMES W. TELLO 

1025 Connecticut Avenue, N.W., Suite 1000 

Washington, D.C. 20006 

Phone: (202) 399-1918 

Fax: (202) 478-0244 

E-mail: jamestello@earthlink.net 

Attorney for 

CHAMPLAIN ENTERPRISES, INC. 

d/b/a COMMUTAIRIUNITED EXPRESS 

June 8, 2011 
BEFORE THE 


FEDERAL AVIATION ADMINISTRATION 


WASHINGTON, D.C. 


* 

In the Matter ofthe Petition of * 

* 

CHAMPLAIN ENTERPRISES, INC. * 

d/b/a COMMUT AIRIDNITED EXPRESS * Regulatory Docket No. 

* 

for an exemption from FAR 121.344(e) * 

* 

PETITION FOR EXEMPTION 

Pursuant to 14 C.F.R. Section 11.25, Champlain Enterprises, Inc. d/b/a 

CommutAirlUnited Express ("CommutAir" or the "Petitioner") hereby petitions for exemption 

from 14 C.F.R. 121.344(e), to the extent required to permit the operation of Bombardier Q-300 

aircraft N839CA and N837CA (both manufactured between August 18,2000, and August 19, 

2002) using 34 parameter digital flight data recorder, or for such alternative relief as otherwise 

requested here. In accordance with 14 C.F.R. Section I1.8I(f), a summary ofthat request is 

attached as Exhibit 1 to this application. 

PRIMARY RELIEF REQUESTED 

1. The Company is an air carrier certificated by the FAA pursuant to FAR 119 and 

holding operations specifications issued pursuant to FAR 121 which permit domestic, flag and 

supplemental operations. 

2. FAR 121.344 requires the installation of a digital flight data recorder for 

turbine-engine powered transport category airplanes that records a varying list of parameters 
depending upon when the airplane was manufactured, providing that in certain noted instances, 

no change in installed equipment is required to obtain the specified parameter. The Bombardier 

Q300 aircraft is subject to this rule, and the parameters specified for the DFDR system required 

are set forth in 121.344( d) (34 parameters for aircraft manufactured after October 11, 1991); (e) 

(57 parameters for aircraft manufactured after August 18,2000); and (t) (88 parameters for 

aircraft manufactured after August 19, 2002). 

3. There are a total of 14 Dash 8, Series 300, airplanes in FAR 121 service, all of which 

have manufacturing dates consistent with a DFDR having no more than 34 parameters - dates 

prior to August 18,2000. There were 33 Series 300 airplanes built by Bombardier after August 

18,2000 and before August 19,2002, and, therefore, subject to 121.344(e). However, none 

were sold for air carrier service in the United States.! For that reason, Bombardier never 

designed a Series 300 aircraft for the 57 parameter installation required for these aircraft to be 

operated in the United States. (Some Q300 aircraft were manufactured after August 19,2002, 

with an 88 parameter DFDR. None are at issue here.) 

4. CommutAir signed a contract to acquire the two aircraft that are the subject ofthis 

application from Tyrolean Airways earlier this year. (The second is subject to a closing 

estimated to be at the end of June 2011.) The conformity inspection was commenced on the 

first aircraft and in May 2011 the discovery was made that the aircraft did not conform to the 

DFDR requirement at issue here and could not be readily upgraded to the 57 parameter DFDR 

required. The aircraft were operated previously under European standards with a DFDR 

recording 31 parameters. However, they could be upgraded to 34 parameter installations in 

accordance with Timco STC No. STOI929AT-D. See also Exhibit 2. Thus, these two aircraft 

can readily be modified to conform to the standards of all ofthe other Q300 aircraft now 

operating in the United States (all with 34 parameter DFDRs) and CommutAir plans to do so 

! Source: Bombardier. 

2 

prior to operating these aircraft. Three other Q300 aircraft were acquired contemporaneously, 

but those aircraft were manufactured prior to August 18, 2000, and conformity to the appropriate 

34 parameter standard is readily achieved through use ofthe Timco STC. Thus, the 57 

parameter requirement applies to only two Q300 aircraft, the two at issue here, and Bombardier 

has no plans to manufacture any more Q300 aircraft. 

5. All of the Q300 aircraft that were acquired by CommutAir are intended to fly under 

contract with United Airlines, Inc., C"United") as United Express. The air service offered by 

CommutAir will provide unsubsidized service in small to medium sized cities throughout the 

upper Midwest and Northeastern United States to United's hubs. The service performed by the 

Q300 will replace flights on routes that otherwise would be uneconomical to serve using less 

fuel- efficient aircraft with similar seating capacity, thus affording the public in those market 

areas additional air transportation support for their local businesses. 

6. Without the relief requested here, CommutAir will not be able to fully implement its 

contract with United and those additional transportation services may not be available to those 

communities. By contract, CommutAir is obligated to commence service no later than June 29, 

2011. Thus, our primary request for relief is to permit the operation ofthose two airplanes with 

the 34 parameter DFDRs used by all other Q300 airplanes now in FAR 121 operation in the 

United States. 

ALTERNATE RELIEF REQUESTED 

7. Ifthe FAA is not prepared to grant the primary relief requested and permit these two 

aircraft to operate with 34 parameter DFDR's, the Company will be required to apply for a 

supplemental type certificate for the installation of a 57 parameter DFDR for installation solely 

in two aircraft, all ofwhich will require the expenditure of about $500,000.00 for the two aircraft 

and a time period of about 12 months. That sum and that effort would be a significant financial 

3 

burden to CommutAir, which now operates a fleet comprised of only 16 Q200 airplanes. If 

those two aircraft could not operate in revenue service during the intervening period when the 

STC is developed and implemented, lower revenue levels and some concomitant reductions in 

both service and employment must be expected. In the event that the primary request for relief 

is denied, CommutAir asks the alternative relief described in the following paragraphs on the 

grounds stated. 

8. CommutAir has contracted with a designated engineering representative and 

certification manager to assess what might be required to develop such an STC? The elements 

ofthe STC proposed would include the same flight data acquisition unit (FDAU) as installed on 

the Q300s manufactured to accommodate 88 parameters and a new DFDR that could 

accommodate the 57 parameters required. A more complete description is presented in the 

attached summary prepared by the DER. Exhibit 2. In any case, the equipment and installation 

would conform to all requirements of FAR 121.344( e) in the process of approval ofthe STC by 

the FAA.3 

9. If the preparation and implementation ofthis STC is required, that process is estimated 

to take a minimum oftwelve months after commencement in accordance with the schedule 

2 Rick Veronan (DERT955 1 I 8NE), Design Maintenance Analysis, inc., P.O. Box 570, Georgetown, DE 19947. 

3 An exemption from parameters 37 (drift angle), 47 (selected barometric reading), 50 (selected Mach), and 57 

(thrust command) as specified by FAR 121.344(e) and Appendix M to that rule is not really necessary because 

installation of a DFDR with those parameters is not necessary when to do so would "require a change in installed 

equipment." Information sources for those parameters are not installed in the Q300 aircraft. FAR 121.344{a). 

Parameter 42 (throttle/power lever position) is not required for aircraft like the Q300, an aircraft with mechanically 

linked cockpit engine controls. Parameter 43 is already present. FAR 344( e), Appendix M. Parameter 41 

(windshear detection) is not required since the DHC-8 as a turbo-propeller powered aircraft does not have a 

windshear detection system. Parameter 56 (Multi-Function Engine Alerts) is not required as the aircraft does not 

have multifunction engine displays. 

Accordingly, the exemption may be limited to parameters 35 (GPWS), 36 (landing gear position or landing gear 

cockpit control selection), 38 (wind speed and direction), 39 (latitude and longitude from GPS), 40 (stick pusher and 

shaker activation), 44 (TeAS), 45 (DME 1 and 2 distance), 46 (Nav land 2 selected frequency), 48 (selected 

altitude), 49 (selected speed), 51 Selected Vertical Speed, 52 (selected heading), 53 Selected Flight Path, 54 

(selected decision height), and 55 (EFIS display format). 

4 

attached as Exhibit 3. That is a very aggressive schedule that we are assured is possible with the 

cooperation ofthe relevant FAA offices. 

10. No reduction in operational functionality will be experienced during the period that 

the exemption will be in force for those two aircraft. The aircraft will also have a fully 

equivalent level of safety to every other Q300 operating in FAR 121 revenue service in the 

country - all of which use 34 parameter DFDRs. Thus, this exemption will not adversely affect 

safety. 

11. An exemption from the parameters specified by FAR 121.344(e) numbered from 35 

to 57 in, as referenced and specified in Appendix M, is requested for the duration ofthe period of 

development and implementation of an STC to the extent necessary to permit continued 

operation of aircraft N839CA and N837CA in air carrier service. 

DISCUSSION 

As the overview of the history ofthe development of this rule describes,4 the rule was 

not intended to force the retrofit of aircraft that are out of production or of aircraft the number of 

which is "small and declining, such that any safety return from expended FDRs would be 

minimal." Revisions to Digital Flight Data Recorder Rules; Proposed Rule, 61 FR 37144 at 

37153 (July 16, 1996) (discussing the exclusion of certain aircraft from the rule). That 

consideration also rested explicitly upon the unjustified cost of that retrofit. Id. Moreover, it 

appears that anticipated retrofits focused on the 34 parameters required for aircraft manufactured 

before 1991. Id., 61 FR at p. 37152. See also discussion in Exhibit 2. Accordingly, the policy 

of the rule should allow consideration of an exemption that is applicable to the only two aircraft 

in this position (Le., otherwise required to upgrade) that will be in air carrier service in the U.S. 

4 Exhibit 2. 

5 

The FAA has readily granted exemptions from FAR 121.344. Continental Airlines. Inc., 

Exemption No. 7323 (August 21, 2000); American Eagle Airlines, Inc., Exemption No. 7319 

(August 18,2000); Mesa Airlines, Inc., Exemption No. 7324 (August 21,2000); Chautauqua 

Airlines, Inc., Exemption No. 30171 (August 21, 2000); Delta Airlines. Inc., Exemption No. 

8709 (April 17, 2006); Delta Airlines, Inc., Exemption No. 8709A (November 29,2007). 

Exemptions have been granted for multiple parameters, multiple airplanes, and, particularly, for 

the period needed to update the aircraft. This is not a case where the manufacturer had notice of 

a required change in the installation of a DFDR and did not implement a timely design change 

for aircraft to be operated in the United States. No non-compliant Q300 aircraft were 

manufactured for air carrier service in the United States. They were all manufactured to be 

off-shore or for private or government use. Moreover, the FAA has recognized that permitting 

an aircraft to be operated while upgrading the DFDR is in the public interest. "The result of 

grounding the airplanes would be cancelled flights, disrupted schedules, and significant financial 

loss, inconvenience, and lost time cost to the travelling public, with no discernable safety 

benefit." Delta Airlines, Exemption No. 8709, supra. 

The issuance of an exemption for either the primary requested relief, which would relieve 

CommutAir of an expenditure of $500,000 for an STC only applicable to two aircraft, or for the 

alternative relief for an interim period of one year in which the airplanes could operate while an 

appropriate STC is developed, are both in the public interest. Both would continue a 

comparable level of safety experienced by every air carrier now operating the Q300 in the United 

States and would not adversely affect safety. 

CommutAir further requests that the FAA waive publication and comment on this 

petition. Good cause is shown by this petition for such action because the delay that may result 

from publication would frustrate its purposes. The need for this exemption was not apparent until 

6 

a conformity inspection in May 20111 and this application is filed as soon as it could be prepared 

with fully descriptive data. It would also not set a precedent. 

CONCLUSION 

WHEREFORE, on the basis ofthe foregoing, Champlain Enterprises, Inc., d/b/a 

CommutAirlUnited Express, requests issuance of an exemption from FAR 344( e), 14 C.F.R. 

344(e) to the extent necessary to permit the operation of aircraft N839CA and N837CA, 

Bombardier Q300 series aircraft in air carrier service, without conformity with the parameters 35 

through 57 as described in FAR 121, Appendix M either, (a) for the duration of their operation 

by the Petitioner or, (b) for a period oftwelve (12) months from issuance while an appropriate 

STC is developed and a DFDR that conforms to the cited requirements is installed in those 

aircraft. 

s~dr1/

f~ ames W. Tello 

CES OF JAMES W. TELLO 

1025 Connecticut Avenue, NW 


Suite 1000 


Washington, DC 20036 


Phone: 202-399-1918 


E-Mail: jamestello@earthlink.net 


Counsel for 


CHAMPLAIN ENTERPRISES, INC. 


d/b/a COMMUT AIRIUNITED EXPRESS 


June 8, 2011 

7 

EXHIBIT 1 

FEDERAL REGISTER SUMMARY 

Champlain Enterprises, Inc., d/b/a CommutAir/United Express ("Petitioner'), requests issuance of an 

exemption from FAR 344(e), 14 C.F.R. 344(e) to the extent necessary to permit the operation of aircraft 

N839CA and N837CA, Bombardier Q300 series aircraft in air carrier service, without conformity with the 

parameters 35 through 57 as described in FAR 121, Appendix M either, (a) for the duration of their 

operation by the Petitioner or, (b) for a period of twelve (12) months from issuance while an appropriate 

STC is developed and a DFDR that conforms to the cited requirements is installed in those aircraft. 
EXHIBIT 2 

DMA INC 


POST OFFICE Box 570 

GEORGETOWN DE 19947 

June 7, 2011 

James W. Tello 

Law Offices of James W. Tello 

1025 Connecticut Avenue, NW 

Suite 1000 

Washington, DC 20036 

Dear Mr. Tello: 

Enclosed is a brief history of FAR 121.344 and the Timco alteration to result in compliance to FAR 

121.344(d). Some of the information is based on my participation of the Aviation Rulemaking Advisory 

Committee assembled to assist in the development of the rule, while other information is public record. 

Additionally there is a description of the physical changes required to the DHC-8-311 aircraft under 

contract to CommutAir in order to comply with FAR 121.344(e). 

The current operating rule, FAR 121.344, on flight data recorders for US scheduled airlines is the result 

of an Aviation Rulemaking Advisory Committee (ARAC) assembled in the late 1990's. This committee 

included personnel from the National Transportation Safety Board (NTSB) the FAA, aircraft 

manufacturers and airline operators representing the Air Transport Association (ATA) and the Regional 

Airline Association (RAA). 

I participated on the ARAC as a representative of the RAA. Accordingly this is a first person history. The 

goal of this group was to develop a requirement to upgrade flight data recorder systems on all aircraft 

that were currently being produced or that were in Part 121 service in significant numbers. The result of 

this upgrade would be that except for a small number of aircraft operated in very small numbers all 

aircraft would have a minimum standard that would include the position of the flight control and the 

pOSition of the flight control surface. The actual number of parameters that would be required varied 

depending on the architecture of the original flight data recording system. The intent was to reach a 

minimum standard within the capacity of the existing recorder architecture, yet use all existing capacity 

according to a standard developed by the NTSB. The final number of parameters required ranged from 

18 parameters for aircraft without a Flight Data Acquisition Unit (FDAU) to up to 34 parameters for more 

current aircraft. The rule recognized the difficulty in developing a retrofit system that would record 

more than 34 parameters so the rule as written did not intend to require any retrofit beyond the 34 

parameter system. 

To support the conclusion that the neither the FAA nor the ARAC intended for retrofits to require more 

than the initial 34 parameters I have provided the following excerpt from the Revisions to Digital Flight 

Data Recorder Rules: Proposed Rule, 61 FR 37144 at 37153 (July 16, 1996), addressing the potential rule 

change. I have made a portion of the excerpt bold for amplification. 

Taking into account the NTSB concern that all new airplanes be able to record the maximum number of parameters, balanced 

against the knowledge that airplanes in production carmot be re-engineered without sufficient lead time, the FAA has 

determined that FDR requirements for future airplane production will be based on the date of manufacture, but that the 

dates suggested by the NTSB cannot realistically be met without incurring overwhelming costs and unacceptable 

delays in production. Accordingly, the proposed rule would place the following requirements on newly manufactured airplanes. 

The first group of airplanes, addressed in proposed § 121.344(d)(I), are those manufactured after October II, 1991, 
DMA INC 


POST OFFICE Box 570 

GEORGETOWN DE 19947 

but on or before [insert date three years from effective date, i.e. 2000) to record the parameters listed in paragraphs 

(a)(l) through (a)(34), and do so in accordance with Appendix M. Similar to the requirements for older airplanes, the parameters 

listed in paragraphs (a)(12) through (a)(l4) could be recorded from a single source. Proposed § 121.344(d)(2) carries forward 

the requirements that all additional parameters that are within the capacity ofthe recording system must also be installed 

to take advantage ofthe latest advancements in technology and the capabilities of individual airplanes. Because this 

requirement will apply to airplanes recently produced, it is a retrofit requirement, but the effect of the retrofit is softened 

by limiting the requirement to the first 34 parameters. 

The ARAC, the NTSB and the FAA also considered the cost benefit of aircraft that were not in production. 

While at that time the DHC-8 Series 300 was in production, Bombardier no longer actively produces this 

model. An additional excerpt from the same Federal Register publication shows the following. 

Paragraph (1)(2) lists those airplanes that are out of production. After considering analysis of data presented by aircraft operators 

and manufacturers, the ARAC working group determined that the remaining economic life of these airplanes is insufficient to 

justify the cost associated with extensive DFDR retrofit. Further, the number of these airplanes in operation is sufficiently 

small and is declining, such that any safety return from expanded FDR's would be minimal. 

The rule was never intended to require a significant retrofit to only two aircraft, particularly when there 

are limited numbers of aircraft to benefit from any possible accumulated data. 

Beyond the requirements for addressing the existing fleet, the group prescribed standards to be met by 

aircraft to be manufactured in the future, since future aircraft were not constrained by existing system 

architecture. These requirements were for recorder systems to record 57 parameters on a date three 

years after the effective date of the rule and for them to record 88 parameters five years after the 

effective date of the rule. 

In order to comply with the rule, all Part 121 operators of DHC-8 aircraft formed a group and developed 

a means of compliance and submitted it to various alteration agencies for proposals. Timco was 

awarded the contract. There were two versions of alterations developed by Timco. One modification 

addressed older DHC-8 Aircraft that had been recording 17 parameters and a second STC ST01929AT-D, 

was developed for newer DHC-8 aircraft that were recording 31 parameters. This second STC added 

sensors and changed FDAU software to add the parameters of Roll, Pitch and Yaw control input 

positions. All DHC-8 Series 100 and 300 aircraft in Part 121 operations in the United States have flight 

recorder systems upgraded by one of these two STCs. It should be noted that these STCs were not 

issued until nearly two years after the effective date of the rule, even though the operators had been 

actively engaged in compliance plans prior to the final rule. 

The aircraft acquired by CommutAir were previously operating in Europe and were not required to meet 

the requirements of FAR 121.344. They currently comply with FAR 121.343 (f). These aircraft can be 

upgraded to a 34 parameter system by accomplishing TIMCO STC ST01929AT-D. This would result in 

compliance to FAR 121.344(d) by installing sensors for the roll, pitch and yaw control positions and a 

discrete sensor for control column separation. However, there is currently no existing retrofit available 

to upgrade this aircraft for compliance to the 57 parameter system required by FAR 121.344(e). 

Bombardier has never developed a recorder system for a 57 parameter flight recorder system for any 

model of the DHC-8. Bombardier has developed a system for recording 88 parameters on late model 

DHC-8 aircraft. This modification installs a 256 word per second flight data recorder (FOR) in lieu of the 

64 word per second recorder found on the earlier aircraft. A new model PN 2244000-511 FDAU capable 

of the increased number of parameters is installed. These newer aircraft have the additional sensors 
DMA INC 


POST OFFICE Box 570 

GEORGETOWN DE 19947 

installed and additional wire harnesses for transmitting data from the new sensors and from other data 

sources to the FDAU and to the FOR. The wiring for these changes was initiated in production 

approximately at production serial number 595. However, there were aircraft produced well after this 

point that did not have the sensors installed or the new FDAU and FOR. 

Bombardier has provided service bulletins 8-31-24 and 8-31-25 to install the new sensors, OFAU and 


FOR's on two aircraft serial numbers 619 and 635. These aircraft were required to have the additional 


parameters by the Japanese Civil Aviation Bureau (JCAB). This is the only known retrofit of aircraft with 


an older 31 parameter system to a system capable of compliance to FAR 121.344{e). While these 


service bulletins provide a system more capable and complex than that required by FAR 121.344(e), 


adapting this data provides the most expedient method of compliance. However, these bulletins 


addressed aircraft with aircraft wiring developed for the additional parameters already installed. While 


this 


If compliance to FAR 121.344(e) is required for aircraft Serial Numbers 553 and 554 the following 


changes to the aircraft must be developed by CommutAir and approved by the FAA. 


Replacing the existing 64 word per second recorder with a 256 word per second recorder. 


Replacing the existing FOAU with a Part Number 2244000-511 FOAU. 


Installing two each sensors one at each end of the elevator layshaft under the flight deck floor. 


Installing two sensors, one on each roll control sprocket under the flight deck floor. 


Installing one sensor on the rudder quadrant under the flight deck floor 


As previously stated Service Bulletins 8-31-24-and 8-31-25 provide data that may be available for 


accomplishing some or all of the above steps. This data may be able to be adapted and reduce the time 


required to develop a retrofit. FAA approval would still be required, since the Service Bulletins are not 


being accomplished as written. 


The service bulletins assumed the aircraft already had the advanced wiring to support these 


installations. This wiring would have to be developed to retrofit an older aircraft. Additionally the wire 


harnesses and wire routing would have to be developed to support a retrofit application rather than a 


production installation as often production wire routing is cannot be duplicated once the aircraft is built. 


In addition to the above sensors wiring must be installed between the existing Flight Management 


System (FMS) and the FDAU. This will allow recording ofthe latitude and longitude, wind speed and 


wind direction and ground speed. 


The service bulletin data includes wiring and sensors for many additional parameters beyond the 57 


required by FAR 121.344(e). It is recommended that these be installed only if necessary for operation of 


the FOAU to Simplify data development and reduce retrofit complexity. As stated earlier, this system 


was never intended to be installed as a retrofit on aircraft not factory provisioned. 


I have outlined a time table for accomplishment of the retrofit upgrade to the 57 parameter system, but 


it is a very aggressive schedule. This is enclosed with this letter. The original STC to go from 31 to 34 


parameters did not require a total replacement of the FOAU, but only an upgrade, yet it took nearly 2 


years. Additionally the cost to develop the data was spread out over all OHC-8 aircraft in operation at 


that time, rather than the two aircraft involved in the current project. 

DMA INC 


POST OFFICE Box 570 

GEORGETOWN DE 19947 

I hope this assists you in developing a course of action for CommutAir. 

If you have any additional questions, please contact me. 

Regards, 

R. W. Veronen 

President DMA Inc. 

CC: James Page CommutAir 

Joel Raymond CommutAir 

Enclosed: Timeline 
EXHIBIT 3 

DMA INC 


POST OFFICE Box 570 

GEORGETOWN DE 19947 

TIMETABLE FOR SUPPLEMENTAL TYPE CERTIFICATE 

FOR Q300 AIRCRAFT WITH 57 PARAMETER DIGITAL FLIGHT DATA RECORDER 

Explanation of table: Items with bold italics are critical path items. Predecessors are noted. For 

example, obtaining FAA approval of the Certification Plan (PSCP) normally would precede issuing 

requests for conformity (RFCs). 

I Research on Best This step is collapsed since the choice of the No additional time expended 

approach Bombardier system has been made. 

Develop Project Four weeks after program launch 

i Specific Certification 

Plan (PSCP) Submit 

STC Application 

form 8110-12 

• Obtain Project Typically 30 days after submittal 

I Notification Letter of application. 

PNL 

Obtain approval on This is normally required prior to any Typically faur to six months 

PSCP from FAA requests for conformity (RFCs). after submittal of pSCP. 

Procure FDAU for Assume 30 days to coordinate with Teledyne 150 days after start 

Project and Bombardier on dash number and 

procurement details. 

I Purchase sensors 180 days after start 

I and other Line 

i replaceable units 

I LRUs 

Develop wiring This assumes we can find a team with 180 days after start 

diagrams and immediate availability for data development. 

drawings We will need to prioritize items and will take 

time for manufacture and get those drawings 

I released first. 

Develop Kits and Can start manufacturing long lead items after Can Finish within 90 days of 

manufacture parts those specific drawings are complete. drawing release. 270 days 

not procured in i If work is accomplished at CommutAir, the elapsed after start. 

i steps above applicant will have to appoint a CommutAir 

person to act as an agent in completing 

8130-9 tags 

• Obtain FAA approval 2 weeks after drawing release 

· of manufacturing 

I drawings 

Conform Parts and 2 weeks after kits are completed 

I kits 284 elapsed days from start. 

Develop Instructions These must be submitted to the FAA at least 60 days after drawing release 

for continued 30 days prior to STC issuance. 60 days is 

airworthiness ICAs much safer. I 
DMA INC 

POST OFFICE Box 570 

GEORGETOWN DE 19947 

Installation of kits Allow three weeks for first aircraft as the 

installation is subject to conformity. If work 

is accomplished at CommutAir, the applicant 

will have to appoint a CommutAir person to 

act as an agent in completing 8130-9 tags. 

3 weeks after kits are 

conformed. 315 total days 

elapsed. 

Installation 

Conformity 

7 days after installation is 

complete. 322 total days 

elapsed. 

Ground test 7 days after install conformity. 

329 total days elapsed. 

Prepare final reports 

for submittal 

6 days after ground test. 335 

total days elapsed. 

STC issuance This is a normal quick turn for the FAA. 3 weeks after final report 

submittal. 356 total days 

elapsed.